Fine Amount: €2,500,000 total
Carat GP: €300,000
Jimmy Guinet: €200,000
Sébastien Renaud: €2,000,000
Primary Violation: Failure to act honestly, loyally and professionally toward clients
Relevant Period: 1‑Jan‑2019 > 30‑Jun‑2024
Overview
The AMF’s Commission des sanctions fined Carat GP and its co‑managers Jimmy Guinet and Sébastien Renaud a combined €2.5 million, and imposed bans from acting as conseiller en investissements financiers (CIF), for multiple compliance failures.
The decision cites failures in product governance, conflicts‑of‑interest management, complaints handling, AML/CFT controls, and client documentation; together with “unidentified placements” proposed by a manager and deficient cooperation with AMF inspectors.
The AMF initiated a control review of Carat GP on September 1, 2023, covering primarily January 2019 to January 2024. The firm, registered as a CIF from December 2018 to March 2025, was found to have systemic failures in its organization and compliance frameworks.
These included lacking secure archiving tools, incomplete procedures for product governance, conflict of interest management, complaint handling and anti-money laundering (LCB-FT).
Additionally, Carat GP failed to maintain required client documents such as entry relations, mission letters, client questionnaires, adequacy declarations, and cost disclosures for subscriptions advised between January 2020 and January 2023.
The commission highlighted that the firm advised clients to transfer funds for 15 unidentified placements, totaling undisclosed amounts from 10 clients, without proper documentation or verification. Personal grievances against Renaud involved receiving client funds not tied to CIF remuneration and skipping annual training, while Guinet was cited for not addressing known issues with these placements.
Both managers were held personally accountable for the firm's breaches due to their roles. The decision underscores the AMF's emphasis on robust internal controls to protect client interests in financial advising.
From January 1, 2019, to April 24, 2024 (or at least September 30, 2022), Carat GP lacked any formal procedure for product governance, violating Article 313-20 of the AMF General Regulation.
Even after establishing a procedure in October 2022, it remained incomplete until June 11, 2024, missing operational implementation. This affected all client advice, with no evidence of market targeting or product approval processes, impacting the firm's ability to ensure suitable investments for its portfolio of corporate and individual clients.
Carat GP had no procedure for identifying and managing conflicts of interest from January 1, 2019, to April 24, 2024 (or at least September 30, 2022), breaching Articles 325-29 and 325-30 of the AMF General Regulation.
The procedure adopted in October 2022 was incomplete, lacking a dedicated register for logging conflicts. Operationally, no conflicts were recorded despite potential issues, such as dual roles in insurance and banking, leading to unmitigated risks for clients over the 5-year period.
Example: Carat invoiced €2,800 to issuer V for advice on a bond issue, then advised at least 3 clients to subscribe €440,000 to V’s bonds; none of these potential conflicts were entered in the conflicts register.
For all CIF clients subscribing between January 8, 2020, and January 31, 2023, Carat GP failed to establish or maintain complete regulatory documents, contravening Articles L. 541-8-1 and 325-5 to 325-17 of the Monetary and Financial Code and AMF regulations.
This included missing or non-compliant entry relation documents, mission letters, client questionnaires, adequacy declarations, and cost information for an undisclosed number of clients (portfolio comprised professionals, employees, and retirees).
Between January 1, 2020, and January 31, 2024, Carat GP facilitated transfers from 10 clients for 15 unidentified placements proposed by co-manager Renaud.
Funds were collected without documentation or verification of placement existence, with approximately €4 million involved across 16 persons per related reports. No operational safeguards were in place, and Guinet, aware via at least two clients, took no corrective action like notifying authorities.
The total fine amounts to €2.5 million, broken down as follows:
"La Commission a retenu que Carat GP n’avait pas agi d’une manière honnête, loyale et professionnelle car l’un de ses gérants, M. Renaud, avait profité de ses fonctions pour proposer à plusieurs clients de réaliser des investissements sans les documenter, sans que Carat ne mette en place un dispositif permettant de prévenir ou détecter un tel comportement." (From the AMF decision summary)
"La Commission a, pour la première fois, retenu des manquements à l’égard des dirigeants de la société à titre personnel." (From the AMF press release)
"de ne pas avoir apporté son concours avec diligence et loyauté à la mission de contrôle, entre le 22 janvier et le 11 juin 2024, en ayant fourni des informations erronées sur le nombre de clients CIF, en n’ayant pas remis à la mission de contrôle les pièces demandées en dépit des relances adressées et sans fournir de justificatif adéquat." (From the AMF notification of grievances)